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Policy researchers have offered two classes of theories of consumer regulation. One emphasizes the role of business in proposing and shaping consumer protection policies. A second set of theories emphasizes the discretion and initiative of regulators. Through a comparative study of the emergence of consumer protection policies in France and Germany during the 1970s, this article shows that neither of these classes of theories explains the patterns of regulation that emerge. On the one hand, business interests were nearly identical across the two countries, yet regulatory outcomes were starkly...

Policy researchers have offered two classes of theories of consumer regulation. One emphasizes the role of business in proposing and shaping consumer protection policies. A second set of theories emphasizes the discretion and initiative of regulators. Through a comparative study of the emergence of consumer protection policies in France and Germany during the 1970s, this article shows that neither of these classes of theories explains the patterns of regulation that emerge. On the one hand, business interests were nearly identical across the two countries, yet regulatory outcomes were starkly different. On the other hand, national regulators that advocated consumer protections faced strong societal pressures as they selected the regulatory trajectory their country would follow. In France, in particular, consumer policy was characterized by significant experimentation, failure, and reassessment.